On November 18, 2021, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation jointly announced the approval of a final rule to improve the sharing of information about cyber incidents that may affect the U.S. banking system. The rule applies to […]
Enforcement
Belgian Supreme Court rules that Data Protection Authority may impose administrative fines even where a data subject’s personal data were not processed
The Belgian Supreme Court ruled in a judgment of Oct. 7, 2021 that a data subject has the right to lodge a complaint with the Data Protection Authority against a processing practice that violates the GDPR (in this case, the data minimization principle in Article 6 of the GDPR), even where the data subject’s personal […]
FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events
On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of proposed rulemaking that would require reporting to the FTC of certain cybersecurity events. Revisions to the Safeguards Rule Effective since 2003, […]
Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021
By Kim Peretti, Brian Frey, and Kristen Bartolotta On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this year. FinCEN examined ransomware-related Suspicious Activity Reports (SARs) filed between January 1 […]
Department of Justice Announces New Cryptocurrency Enforcement Team
by Kim Peretti and Kristen Bartolotta On October 6, 2021, Deputy Attorney General Lisa O. Monaco announced the creation of a National Cryptocurrency Enforcement Team (NCET). This team was created to tackle complex investigations and prosecutions of criminal misuses of cryptocurrency, particularly crimes committed by virtual exchanges and money laundering infrastructure actors. Because of the […]